Flash light sources are not as such exempted from EU Energy Labelling: they are in scope if they meet the requirements of Article 2(1) of Commission Delegated Regulation (EU) 2019/2015.
If flash light sources can be set at the mode of steady light, this is the mode to be considered. If instead these lights only flash, this is normally due to some form of lighting control. The definition of ‘on-mode’ power (from Commission Delegated Regulation (EU) 2019/2015 Annex I (24)) says that lighting controls should be disconnected or switched off. This is also repeated in Annex I (27), in the definition for “Reference control settings”. If the control is instead fully integrated in the light source, we acknowledge that it might be difficult to switch it off. In general standards require light sources to reach a stable operation before starting the test. To be in this situation, it is important to know how to guarantee that a steady light is not possible.
In case the flash light source cannot in any way be forced to reach a steady state, this light source is not in scope because it is not possible to measure it according to the regulation.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.